ORANGE COUNTY

SHERIFF'S DEPARTMENT
OFFICE OFTHE SHERIFF

550 N. FLOWER STREET

SANTA ANA, CA 92703
(714) 647-7000
WWW.OCSD.ORG

SHERIFF-CORONER
SANDRA HUTCHENS

April 14,2015

C.D. Michel, Esq.

Senior Counsel, Michel & Associates, P.C.
Attorneys at Law
180 East Ocean Boulevard, Suite 200
Long Beach, CA 90802
Telephone: (562) 216-4444
Fax: (562) 216-4445

Dear Mr. Michel,

Thank you for your interest in the current Carry Concealed Weapon (CCW) licensing policy of
the Orange County Sheriff's Department. I appreciate your letter and comments regarding this
Issue.
As you know, state law governing CCW licensing includes a "good cause" requirement. My
position regarding this requirement has not changed. Prior to the Peruta decision in February 2014,
my policies indicated that non-specific, general concerns about personal safety were insufficient.
This has been my position since taking office. As such, I established and maintained CCW policies
that required applicants to articulate their individualized safety concerns and provide supporting
documentation to substantiate those claims. When the Ninth Circuit Court of Appeals initially
published the Peruta decision, I tailored my CCW policies to comply with that decision. After the
Ninth Circuit ordered Peruta be reheard, making the three-judge panel opinion no longer citable
as precedent, I made the decision to revert back to my previous CCW policies until further
direction comes from the court.
Based on the recent change in the Peruta case, our agency conducted an audit of all CCW
applications that were in process in order to determine the next course of action. We have
identified approximately 2,500 applications that were in various stages of the process as of March
26,2015. About 1,700 of those applicants' good cause statements had already been approved and
the applicants were referred to the training requirement for further processing in accordance with
Penal Code section 26202. Applicants whose good cause had been approved will not be required
to provide additional good cause.

Integrity without compromise Service above self Professionalism in the performance of duty Vigilance in safeguarding our community

Mr. Michel
Page 2
April 14, 2015

Roughly 800 applicants were in the earlier stages of the application process and had not received
a good cause determination. Depending on their original good cause, these applicants may be
required to supplement their good cause statements. Our staff is in the process of contacting these
applicants and requesting additional information as needed.
As Sheriff of Orange County, I intend to be responsive to the public's needs while maintaining
high standards of review. This includes CCW applicants meeting the good cause, good moral
character, residency, and training requirements mandated by law and outlined in OCSD Policy
218. Moving forward, I will monitor the Peruta case as it continues through the court system and
make adjustments to our policies to reflect any changes in the legal standard.

Sincerely,

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Sandra Hutch s
Sheriff-Coroner

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